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• • About the Part D Benefit
  • Education and Counseling
  • Medicare Advantage
  • Extra Help
  • General Medicare

The 2009 Part D Calendar Explained

In This Article:

• The Fall 2009 Part D and Medicare Advantage Enrollment Cycle Calendar for Benefits Counselors
• Fall 2009 Calendar and Explanations
• Winter 2010 Calendar Explanations

The Fall 2009 Part D and Medicare Advantage Enrollment Cycle Calendar for Benefits Counselors

Introduction

In the fall of each year, the Medicare Part D and Medicare Advantage timeline heats up. Frequent communications come to your clients from the Centers for Medicare and Medicaid Services (CMS), the Social Security Administration (SSA), and from their Part D and/or Medicare Advantage plans. Each letter is connected to the decisions your clients must make in order to arrive at informed choices about their Medicare coverage for the following year.

 

In this article we help you as benefits counselors to understand the mailings and related events that accompany the Part D and Medicare Advantage open enrollment season each year. We also link to the relevant CMS and SSA materials in order to provide you with a comprehensive head-start for the fall season when your clients make their decisions and enroll for 2010. While the Annual Enrollment Period officially runs from November 15-December 31 each year, your clients begin receiving mailings prior to the official start date.

Enrollment Counseling Suggestion:

Please remind your clients to keep all the letters and other mail they receive in a safe place so that it is available if they need it in the future.

 

Fall 2009 Calendar

Late August 2009                      

Social Security Administration (SSA) Extra Help Redetermination Packets

SSA Letterhead
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The Social Security Administration mails Extra Help (or Low-Income Subsidy, LIS) redetermination of eligibility packets to a sample of those who were found by Social Security to be eligible for Extra Help between May 2008 and April 2009. This year is different because starting in 2010 SSA will not count the cash surrender value of any life insurance as income, nor will they count in-kind support and maintenance (non-cash contributions by third parties towards someone’s food or shelter) as income in determining LIS/Extra Help eligibility. In addition, SSA selects a sample of all Extra Help recipients for redetermination each August. That is why SSA included in this group people who, when they applied for LIS/Extra Help, reported receiving in-kind support and maintenance and/or who reported cash surrender value to their life insurance.

What your clients need to do if they receive a redetermination packet:

The packet contains a questionnaire entitled “Review of Your Eligibility for Extra Help” (Form SSA-1026-OCR-SM-REDE) that must be completed, signed and returned in the pre-addressed, stamped envelope to SSA, preferably within 30 days. Failure to return a completed form results in termination of Extra Help shortly after the beginning of 2010. Any changes to Extra Help status or level are generally effective on Jan. 1, 2010. Remember, the cash surrender value of life insurance won’t count as an asset in 2010, nor will the value of in-kind support and maintenance count as income.

 

Enrollment Counseling Tip:

The form must be completed and returned to SSA even if your client experienced no changes to income or resources that would affect her Extra Help eligibility or level of subsidies.

Find more information from SSA about the 2009 Extra Help redetermination process.

September 15, 2008

 

CMS Loss of Deemed Status Letters                         

(GREY-colored letters)

 

CMS mails notices to all people who lost their Medicaid eligibility as of July 2008, and, therefore, will now also lose their deemed eligibility for Extra Help as of January 1, 2010. This group includes people who lost their entitlement to a Medicare Savings Program. People whose SSI was terminated during 2008 also receive this grey letter.

 

What do your clients who receive this letter have to do?

Your clients' action-steps depend upon their current circumstances when they receive the grey-colored letter. 

• If your clients regained their Medicaid eligibility at anytime from July through December 2009, they should automatically be redeemed for LIS/Extra Help as of the month they again become dually eligible for Medicare and Medicaid through calendar year 2009. CMS should mail them a new deemed-eligible letter printed on purple colored paper, to notify them that they will continue to receive Extra Help through calendar year 2010.

 

• If it appears your clients won’t regain Medicaid entitlement, you can explore with them their potential eligibility for any kind of Medicaid, including but not limited to surplus income spend down or one of the Medicare Savings Programs (QMB, SLMB, or QI). If your client’s appear to be eligible for one of these programs, help them apply as soon as possible.
  
  
• If your clients do not appear to be eligible for Medicaid, you can screen them for eligibility for LIS/Extra Help. If they appear to be eligible, encourage them and help them to apply. The grey letter will include an Extra Help application. Their Part D plan should also be in touch with them by outbound call and letter to urge them to apply for Extra Help. If they have life insurance with cash surrender value or in-kind support and maintenance that might make them ineligible in 2009, they should wait until immediately after New Year’s Day 2010 to apply for LIS/Extra Help.

 

You can also help them to submit their applications electronically on BenefitsCheckUp or the Social Security online application center

 

October 1, 2009

Part D and Medicare Advantage Marketing Begins

Part D and Medicare Advantage plans commence marketing their 2010 Medicare products. They must adhere to the CMS marketing rules and may not make unsolicited contact with your clients except under limited circumstances.

 

2009-2010 Enrollment Cycle Calendar for Part D and Medicare Advantage

Early October

 

CMS Change in Extra Help Level Letters

(ORANGE-colored letters)

 

CMS mails letters on orange paper to people who will continue to be deemed eligible for LIS/Extra Help in 2010, but whose level of Extra Help will change. Some people may go from partial to full LIS/Extra Help because the cash surrender value of any life insurance they own, or in-kind support and maintenance won’t be counted in 2010.

 

What should your clients do if they receive this letter?  

• If your clients’ income or resources changed and the new level of Extra Help is the correct one, your clients need to understand their new co-payments for 2010. If they will only get partial Extra Help in 2010 they need to understand the deductible and premiums they will have to pay.

• If the new level of Extra Help is incorrect you can help them contact their state Medicaid agency to make sure their income and resources have been correctly reported to CMS.

• Like all other people with Medicare, they should review their coverage, compare their options and enroll between November 15th and December 31st in the Part D plan they believe best meets their needs.

 

October 2, 2009

 

Plan Non-Renewal Notices Received

Part D or Medicare Advantage plans that are terminating service as of Dec. 31, 2009, must notify all members in writing by no later than Oct. 2nd. This year, many Medicare Advantage plans, especially Private Fee-for-Service Medicare Advantage plans, are terminating their contracts. This is often referred to as non-renewal.

 

What should your clients do if they receive this non-renewal notice?  

Since their plan will be ending at the conclusion of 2009, your clients must select and enroll in a new plan. They have a Special Enrollment Period (SEP) to join a new plan. Their SEP runs from October 1, 2009 and ends on January 31, 2010. Your clients may select their effective date for their new plan. Depending upon when they enroll, they can select November 1st, December 1st, January 1st, or February 1st. In no event can the effective date precede full submission of the plan enrollment information.

 

LIS/Extra Help beneficiaries will be reassigned to a new plan if they do not select one on their own and also get another notice from CMS about the plan termination explaining the plan to which they have been assigned for 2010.

Mid-October 2009

Plan Finder Active with 2010 Plans

The Medicare Plan Finder on www.Medicare.gov will have 2010 Part D plan data and will default to the 2010 information. Until November 30, 2009, you can switch the view to see 2009 plan information. Starting on December 1, 2009, the 2009 data isn’t accessible because the earliest effective date of plan enrollment in December 2009 is January 1, 2010.

 

October 31, 2008

 

Annual Notices of Change

All Part D and Medicare Advantage plans must make sure that their members receive the Annual Notice of Change (ANOC) by mail. This important document, although lengthy, describes changes to the plan in coverage and costs for 20109. View the 2010 ANOC templates for the different types of Medicare Advantage and Part D plans.

 

What should your clients do with their ANOC?

The ANOC is the key starting point for your clients to review and compare their coverage in order to make informed decisions about their choices for 2010. The ANOC describes the cost and coverage the plan they are in this year, 2009, will offer in 2010. Remember that almost every plan changes its cost and coverage structure from year to year, so even if a plan has the same name for 2010, the plan structure could be very different. Careful review is always the best practice. Using the ANOC as a point of reference, your clients should compare what their current plan will cost and cover in 2010 to what it covered in 2009, and you should also discuss options available from other plans in 2010.

 

Extra Help Rider

Extra Help beneficiaries must receive the plan Extra Help Rider from their Part D provider. This document describes plan premium and costs for Extra Help plan members in 2010.

 

What should your clients do with their Extra Help Rider?

Your clients should review this document and compare it to the Extra Help eligibility notice they received from either CMS or SSA to be sure they are charged the correct amounts.  See the CMS Memorandum to Part D plans about the Extra Help Rider.

Medicare & You 2010

The Medicare & You 2010 handbook is sent from CMS to every household in which someone with Medicare resides.

 

What should your clients do with their Medicare & You Handbook?

This handbook is the primary reference source for people with Medicare. Your clients should retain the handbook in a safe place for future reference.

 

Employer/Union Notices of Creditable Drug Coverage

Every year, employers and unions that offer drug coverage to their Medicare-eligible employees and retirees must provide a notice that explains whether their drug coverage remains creditable for purposes of Part D in the upcoming plan year.  View a model creditable coverage notice or see more information from CMS of creditable coverage .

What should your clients do with their notice of creditable drug coverage?

Your clients should read this notice carefully to understand their rights and obligations. The notice might be in a letter sent to them by their employer or union. But it might also be found in a newsletter or other publication the union or employer gives to employees and retirees. If their drug coverage from their employer or union is creditable, your clients do not have to join a Part D plan. If they decide to join a Part D plan at a later date they will not be subject to the late enrollment premium penalty (so long as they have been continually enrolled in their employer or union sponsored health plan with creditable prescription drug coverage).

 

Late October - Early November 2009

 

CMS Choosers Letter

(TAN-colored letters)

 

CMS sends a letter to the group they call “choosers.” These are people eligible for Extra Help who decided for themselves which Part D or Medicare Advantage plan to enroll in; they did not stay in the plan into which CMS auto-enrolled them when they first became eligible for Extra Help. You may have helped your clients to make these decisions. CMS sends this letter to inform people that the plan they were in during 2010 is either raising their premiums above the low-income benchmark level in 2010, or is going to be an enhanced plan in 2010. CMS will not enroll these “choosers” into a different plan for 2010 - if the beneficiary wants to stay in a plan that qualifies as a low-income benchmark plan, they must enroll in a new plan on their own.

 

What should your clients do if they receive one of these “choosers” notices?

Choosers, like all other Extra Help beneficiaries whose plan premium will rise above the low-income benchmark in 2009, or will become an enhanced plan must decide what plan to join for 2010. CMS does not reassign choosers to another plan with a premium at or below the regional low-income benchmark.

Like all people with LIS/Extra Help, choosers can switch to a plan for which they will pay no premium in 2010, or they may decide to pay a small premium if they decide that a higher cost plan offers better access to their prescriptions. Regardless of the type of plan they join for 2009 they will continue to pay the applicable Extra Help co-payments amounts for their Part D prescriptions that are covered by their plan.

This year, CMS published a chart detailing which part of the premium of every enhanced plan LIS/Extra Help people must pay in 2010. This chart can be a useful tool to you as you do enrollment counseling with your clients who are choosers.

Read more about types of Part D plans.

CMS Reassignment Letter

(BLUE-colored letters)

• Non-renewal reassignment letter
  
  
• Premium going up reassignment letter

 

Two groups of people with Extra Help are being reassigned to different Part D plans for 2010. They receive blue reassignment letters. First, everyone with Extra Help who is in a plan that is terminating at the conclusion of 2009 gets a blue reassignment letter.

Second, full Extra Help beneficiaries in plans that will charge them a premium in 2010 also get a blue reassignment letter.

Find the 2010 regional low-income benchmarks.

Knowing the breakdown of how much of each Part D plan premium is attributable to the basic features of the plan (and covered by LIS/Extra Help) and how much of each plan’s premium is attributable to enhanced features of the plan or above the applicable low-income benchmark here. This will help you to explain how much of an out-of-pocket premium someone with full LIS/Extra Help would have to pay if they enrolled in a plan with a premium above the low income benchmark or an enhanced plan in 2010.

 

What should your clients do if they receive a blue reassignment notice?

Your clients who are in plans that are terminating must join a new plan and if they do not join a plan on their own by the end of December 2009 CMS reassigns them to a new plan.

 

Extra Help beneficiaries whose plan will charge them a portion of the premium in 2010 (either because the plan premium is rising above the low-income benchmark in 2010 or because the plan is becoming an enhanced plan) may decide to stay in their current plan, select a different plan, or do nothing and be reassigned by CMS to a new plan.

If your clients want to stay in their current plan they must call 1-800-MEDICARE or the plan to request to stay in the plan. If they want to switch to another plan they may use the Plan Finder. If they do nothing they will be reassigned by CMS. In all cases, the new plan will become effective on Jan. 1, 2010.

  

November 2009

 

Nov. 15, 2008

2010 Annual Enrollment Period begins.

 

December 2009

 

Social Security Administration (SSA) Cost of Living Adjustment Letter

SSA mails letters to all Social Security beneficiaries to inform them that for the first time in many decades there will be no cost-of-living increase to their benefit amounts for 2010 because there was no increase to the cost of living. The letter contains specific information about the SSA withholding of the Part B premium. View Medicare Parts A and B premium and cost-sharing amounts.

 

Part D plans receive a file from CMS of members losing deemed eligibility for Extra Help as of Dec. 31, 12008

Plans are expected to make outbound phone calls, as well as send a letter to plan members who are losing their deemed eligibility for Extra Help to urge them to re-apply  and offer assistance with the application process. Note that CMS has waived the otherwise applicable marketing prohibition to allow plans to market to the Extra Help members they are losing. Careful benefits counseling will be important.

 

Winter 2010

January 2010

 

2010 Part D and/or Medicare Advantage coverage begins

Special Enrollment Period for those who lost Extra Help as of Dec. 31, 2009

This SEP lasts through Mar. 31, 2010, or until your client enrolls in another plan.

 

Optional Grace Period and Updated Best Available Evidence (BAE) policy

 

Part D plans may, but are not required, to use this special grace period to allow their members who lost LIS/Extra Help as of Dec. 31, 2009, to reapply for LIS/Extra Help. If they do not regain LIS/Extra Help by the end of the grace period (up to 3 months, or the end of March 2010) the plan must retroactively charge them its regular monthly premium, deductible amount, and cost-sharing. See the CMS Memorandum on this grace period – scroll down to Appendix A.

Your clients who have been redeemed or have reapplied and regained Extra Help eligibility can use the Best Available Evidence (BAE) procedure to prove their Extra Help status, if the plan records do not reflect their Extra Help status when they go to the pharmacy to get their prescriptions.

Special Enrollment Period for Members of Non-Renewing Plans Continues until the end of January 2010.

And don’t forget the many Part D and Medicare Advantage Special Enrollment Periods. All Extra Help Beneficiaries have a continuous Special Enrollment Period and can switch plans at any time, with their new plan enrollment effective the first day of the following month.

Transition fill rules govern the first refill of medications made under a new Part D plan.

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